Submissions and Reports

The Chamber commends the Government's ongoing efforts to advance the Northern Metropolis (NM) mega-project and have submitted our latest general recommendations to support its comprehensive development in the short and medium term. Specifically, we have conveyed our members' perspectives on the design and execution of the Pilot Large-Scale Land Disposal Scheme, emphasizing key considerations such as financial and investment aspects, as well as land supply and management challenges. These insights aim to encourage industry participation and foster effective collaboration with the Government in building this new metropolis.

The Chamber largely agrees with the Security Bureau’s proposed introduction of a new legislation to enhance the protection of the critical computer systems of critical infrastructure, acknowledging the significance of safeguarding the cybersecurity of the city’s essential services in upholding Hong Kong's stability and status as a global financial centre. At the same time, the Chamber recommends that consideration be given to putting in place a new regulatory regime that is proportional and balanced, principle and risk-based based, and aligned with international-standards - to facilitate business compliance and stakeholder trust - and which keeps pace with advancements in innovation and technology. We also seek further clarity on the regulatory scope and targets which would help provide certainty to local and international market participants.

The Chamber recognizes the objectives of present industry-led efforts to develop a Voluntary Code of Conduct for ESG ratings and data products providers (the Code), and regards this form of regulatory intervention as a proportionate measure, to foster the growth of a transparent and trusted market for the sector, and to facilitate companies due diligence in light of increasing sustainable investment awareness.
In relation to the design and implementation of the proposed Code, we suggest amongst others, that consideration be given to incorporating suitable flexibility and interoperability to facilitate voluntary adoption by the wider business community, in the light of potential resource and real data provision challenges.

The Chamber generally supports the Government’s proposals to transform Lau Fau Shan into a tech hub and eco-tourism hotspot, in line with its blueprint for the development of the Northern Metropolis. We recognize that such efforts would benefit businesses, particularly the tech sector, through creating opportunities for cross-border corporate synergies and development alongside Qianhai and Nanshan in Shenzhen.
At the same time, we highlight several conceptual and practical issues relating to these proposals, which we suggest that the Government take into consideration when taking forward the megaproject.

The Chamber welcomes the HKEX’s proposals to enhance the GEM Listing regime in light of the recent significant decline of listings. We nevertheless suggest that greater strides should be taken to attract GEM’s main intended beneficiaries – growth and small and medium sized companies (SMEs), who are crucial contributors to Hong Kong’s economy and prosperity as an international financial city – so as to facilitate the success of such reforms. Recommendations on how to achieve such objectives, comprising cost reduction and relaxing financial eligibility requirements for GEM listing, reducing the profit requirement for entry to the Main Board, as well as enhanced promotion and outreach, are also outlined in the response.

The Chamber welcomes the SFC’s introduction of a new regulatory framework for licensed virtual asset trading platform (VATP) service operators as well as proposals to allow retail investors to access services delivered by the former, provided that there is balance between supporting the development and demands in virtual asset trading, and providing robust protection to investors and market integrity. At the same time, the Chamber notes that there exist differences in industry views on the necessity and sufficiency of certain proposed investor protection mechanisms.

The Chamber welcomes the Government’s initiative to update the Talent List to address Hong Kong’s acute talent shortage situation and sustain a competitive economy, and puts forward recommendations on the necessary high-skilled professions for inclusion in the same.

The Chamber welcomes the HKLRC’s proposals to introduce a bespoke law that deals with the proliferation of cyber-dependent crimes given the risks of such illegal acts on Hong Kong’s businesses. The Chamber has also called for a balanced approach in the design of the new law so that other than the objective of protecting public interest, consideration should also be given to upholding business’ legitimate needs.

The Chamber welcomes the notion of an e-HKD as a digital legal tender given the associated benefits that would go towards consolidating the city’s standing as an international financial centre. The Chamber has also put forward design and implementation recommendations on the development of such a Central Bank Digital Currency.

The nature of the consultation, which concerns copyright owners and users, mean that the Chamber was unable to achieve unanimity when responding to some of the Government’s proposals to update Hong Kong’s existing copyright law. As such, the Chamber has called for a balanced approach that takes into account the rights of owners and users, while reflecting views from both perspectives on such proposals as adopting an exhaustive approach on copyright exceptions and introduction of a judicial site-blocking mechanism.